Loading...
HomeMy WebLinkAbout98-00644 I 1 i I , I I , \. " ~ \! ~ :2 a i .1.1 . . - ~ It 'I ~ I:' C '., .... 4.: \It j } '\ . . ~ ~ , H " " . , i i- : { i ,.,' I {: !, / [ 1 " i I , I r ~ :-.... .s ';; ~ , , ~ ~ ~ . ~ ~ . ~ " 1); C) ~ lI:I is M .:..:J~ lUQ 0-" fE~ ~:: Of.~ ~ ()"'j ~6 -;''';:' en ..l"Cf) ~E , .:.1;;..: [C-)O' u::~ ffi I.lJi:n Wa.. j::: ..... :f!: !5 CO :::. C1'I C,) INRE: JUSTIN MADISON HARPER : IN THE COURT OF COMMON PLEAS OF : PENNSYLVANIA - CUMBERLAND COUNTY : NO, q 8- (..'1'1 Q-,--v<.~ 4--- PETITION FOR CHANGE OF NAME AND NOW, comes Petitioner, Kimberly J. Largent, by and through her counsel of record, Bradley L, Griffie, Esquire, and in support of her Petition for Change of Name of her minor son, Justin Madison Harper, respectfully represents as follows: I. Petitioner, Kimberly J, Largent, is an adult individual currently residing at 1930 A Fry Loop, Carlisle, Cumberland County, Pennsylvania, 2, Petitioner is the natural mother of the child, Justin Madison Harper, born June 3, 1983, 3, The natural father of the child is William Madison Harper, an adult individual currently residing in Iceland with a mailing address of P,S,C, 1003, Box I, FPO AE 09778-0301, and who is presently stationed with the United States Navy, 4, The child, Justin Madison Harper, Bge 14, was born on June 3, 1983, in the Portsmouth Naval Hospital, Portsmouth, Virginia, 5, Petitioner and the natural father were married, having separated in 1985 and later divorcing 6, The natural father is remarried, ~ i{ \ 7, The Petitioner and the natural father of the child were married at the time of the child's birth and, therefore, the child has the last name of the natural father, \ l, 8, Since divorce, Petitioner has uscd hcr maidcn name of "Largent" instead of her prior married name "Harper", 9, Since approximBtely March 1985 when the Petitioner and the natural father of the child separated, the natural father of the child has had extremely limited contact with the child and has never had a strong, consistent relationship with the child, 10, Petitioner has repeatedly requested that the Respondent engage in a closer relationship with the child bccause of an emotional need that the child has exhibited to the Petitioner for the natural father to have closer contact with the child, II. Due to the natural father's inability or refusal to maintain a close and strong emotional bond with the child, the child has expressed, on numerous occasions, to the Petitioner that he be pennitted to change his name from Justin Madison Harper to Justin Madison Largent. 12, The child has expressed to the Petitioner grave concern over the fact that other members of the Harper fanlily have a criminal history and criminilJ background, 13, The child has additional concerns over othcr members of the Harper family of his generation who are now enrolled in his school, believing that their bad reputation will Bdversely impact upon him socially and eduCBtionally, 14, The child's cousin is in the same class and grade as the child and that child has a poor reputation, is a poor student and in other ways creates the impression that the "Harpers" are not good students, !: " 15, The child does not wish to hBve the IBst nBme of "Harper" for the reasons stated above, 16. The child is extremely cloae to the Petitioner's extended family, as well as his mother, 17, The child believes in the positive attributes of having the last name "Largent" and believes thBt it will be far more advantageous to him personally, socially and otherwise, than the name "Harper", 18, The child, at the Petitioner's request, has discussed this request for change of name with a therapist and has continued to maintain his desire to have his last name changed to "Largent", believing it will also strengthen him emotionally, 19, The child has not requested that his middle name, "Madison", be changed, which is also his natural father's middle name, 20, The child has expressed a belief that it will also be beneficial to him to have the last name of his mother as he continues to finalize his high school education at Carlisle High School and pursue a post-secondary eclucation, 21, Petitioner believes that the child has thoroughly considered this request and has made a mature decision that is in his best interest and as he desires, WHEREFORE, Petitioner requests your Honorable Court, pursuant to Act of December 16,1982, P,L, 1309, No, 295, 54 Pa,C,S,A, Section 701 et. seq" to: (a) Fix a time, dBte and place for a hearing on this matter; (b) Direct that notice of filing of this Petition and of the hearing in this matter be published once in one newspaper of general circulation in Cumberland County; (c) Direct that notice of filing of this Petition and of the hearing in this matter be published once in the Cumberland County Law Journal; (d) Direct that notice of filing of this Petition and of the hearing in this matter be served upon the nBtural father by certified mail, restricted delivery and first class mail, postage prepaid on the natural father at his last know address; and (e) Enter a decree changing the name of Justin Madison Harper to Justin Madison Largent. Respectfully submitted, GRIFFIE & ASSOCIATES , squire y for etitioner 00 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 I i i , I , I I ~ j..,., I verifY that the statements made in the foregoing document are true and correct, I understand that false statements herein are made subject to the penalties of 18 Pa.C,S, Section 4904, relating to unsworn falsification to authorities, / r---; /) I~/ DATE: Lub..3 91f ~A- ~ 7 i(jMBERL Y J, LARGENT -- \"; I I n ':"j f.") c: t,.._) -II " -., --;J, -r.t' : r.-, PI; :"._7 rll_q >.. .'1,1.;' :,:.- 1. r ~'.'! , .:~- :"6 ' I. f:"; ~. , ':-'1 '-:::':C') U::1 ')~ ;':j ..,J_. :)-;-;-- -::0' ) !~':~~' r':J ;-'-.. fll ~ :':'j :"., .:q .,..., '0 "" I u i , I ',", ~ if I t' I' I ,~ " .'.....'~ '<l- ,\I '" ; -.( III ..<: "\ y\ ~ ~ ~ ~ r~ ~t. . 'f, I' :i r \ :'! ;~ ':, I ','i\ ~ " " .. ..' ~...' "ILCD ('~-"'~ r C.- ,.,rI'i'..,i: CoF T;.jC I :!n 1!!!i!.'QTNiY 98l-iilR ~O Aj'i fl: 54 CUMUl:';V.j(i.) COUNT( PEi~:'JS) LV,\I~I.\ . r Ref: Petition U 98-644 Attachment I agree the following statements are true: 1, 2, 3, 4, 5, 6, 7, and 8. Item 9. I agree in part that the national father has had limited contact, but this is due in part to the minor child's Mother discouraging the relationship. It is also due to the my occupation in the U.S, Navy, which requires transfers to various U,s, cities and deployments overseas, The minor child's Mother was well aware of my occupation prior to the marriage and the birth of our son. Item 10, I agree that the petitioner has requested the Father to engage in a closer relationship with the child, when this was attempted it was rebuffed or visitation limited. Item 11. This statement could be true, but was not mentioned by the child during the most recent visitation which was during the Christmas holiday, This was first mentioned by the minor child's Mother upon my return to my duty station in Iceland. This was not a verbal statement, but an email note. Item 12, Child has never mentioned his concern to me about family member's criminal background that happened before my marriage and his birth. This criminal history happened almost 20 years ago, During my 19 year naval service, I have continuously sustained an exemplary record, I have been personally decorated three times. I feel the minor child should focus on my example and not family history, The minor child's paternal grandmother was recently named Who's Who in American Woman 1997-1998, Item 13. I admit the minor child may have concerns, but his patterns of friendships were set up prior to his cousin enrolling in the same school. His social status should not be impacted by other Harper family members, of his generation, reputations, Item 14. The minor child has consistently maintained excellent academic grades, The fact that the child's cousin may not be as good a student, should in no way create the impression that the "Harper's" are poor students. The teachers may expect more from other cousins based on the minor child's standard of excellence, Item 15, I agree that this statement is true, Item 16. I agree that the minor child is very close with the petitioners extended family and his mother, but part of the reason for this is that contact with the father's family has been restricted to such a degree that the paternal grandmother had to sue to obtain visitation rights with the minor child, ~ since visitation rights were awarded to the paternal grandmother, their relationship has grown exceptionally close. Item 17. I neither agree or disagree with this statement. I feel it is a shallow statement as there is not proof that the Largent name will be more advantageous to him personally, social or otherwise, Item 18, I believe that by merely changing one's last name is not enough to strengthen an individual emotionally. Emotional stability comes from constant encouragement and guidance from internal and external influences in the minor child's life. I do not feel my absence has contributed to his emotional problems. Item 19, I agree that this statement is true, Item 20, for the child the last name I do not feel that it would be more advantageous to have the last name of his mother as oppose to of his father to further his educational goals. Item 21. I do not feel that a minor child of 14 years and 9 months is mature enough to make this overwhelming decision that will effect the rest of his life, I also believe due to the emotional changes a child goes through during adolescent, this is a decision best delayed until adulthood. '.,. ' '. ~ t: \' . I~, ~, ; I ,~. , r , I c= o ~ o U .... o t::. ::s Q) o '" U ::s 41 0 -5 ..c: .... ~ 00 00;;; ra U M bO O-M "'0 = lU_ ....::s ::s eO 0_1"- u ucn- ..0 "t:ll;l.... -;; c > ..... o al 0 p.. c= - " o ta.!! :I:!!l-e:I:.gJ 41 <l ::I en :a i5~UMU " ~~;f " ,~~ . I ';.;. j{: .~, ."i ,'c : ..i. ,! . '111,4 , ~ I ~, . j n , 1 '.; " . '. ?~... P i i ~ 1 C',''.' ::. i.'~j~~':.",. . I , J \ t I r )~ '," II~. ~~..-. \ ,}~ ; .:B ;l:"~ \. "".:)" , ! i. \ f:,:: ", 'G: -;. li~ \ ;' /:1, :.~), , .~~ . '--"".,. r~~...._;~ !.';J, I l' v"-- -."''\...,.... '.1~; . . \'. ~" .A" ,f .'~',!f::!: 1 I ;~ ~~~-- ~ '. ~ ~.' ..' [:,:,: :,' .', . ~ , . . .... I" .; . I"" ....' ~ t ''''', L . I'" . 1, .... r<, \,,; I ~ " .:..-: ~':" 1 ~ :~ .~".;.. :I. ~A'- .~'... I' " . , ( t. " z '" ;:J I ~ ~-~ ~S~ :':t<"IO ~~~ ~~~ I- I i, f' IN RE: JUSTIN MADISON HARPER, a mionor : IN TIlE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : 98-0644 CIVIL : NAME CHANGE PRAECIPE TO THE PROTHONOTARY: Please mark the above-captioned Petition for Change of Name as withdrawn on behalf of the Petitioner, Kimberly J, Largent. GRIFFIE & ASSOCIATES Date: 1'6//9 hJ' I I \) f<.~ '.~" if";' i~,.. ~1 \<' ~, \ (: i:"1 ~' . r '-0 ::t: n '~i1 ..-\ "~- ~,] 1Ii':''' nIt? ') '~;'~'tlJ .;::J;i ~)B ,~,n o :.;j "'M ~ o c: ;,-~ "0\ [I) t_~:' ..',~ T' ' ",-1 o~.\' ~t~ \..~ "(~ -< ,::> ,SJ Cl :~) -, "" Q - -..11 I"